Low-carbon hydrogen definition: Commission’s last chance to leave a hydrogen legacy

As the dust settles around EU election results and Brussels looks towards the EU’s incoming leaders, one last policy hurdle sits on the desks of energy officials: a definition of low-carbon hydrogen. Energy Commissioner Kadri Simson has indicated the Commission intends to propose a definition by the end of the year.

Jochen Bard, co-founder of the Hydrogen Science Coalition and Director of Energy Process Technology Division, Fraunhofer IEE

Since leading global policy action with its 2020 hydrogen strategy, the bloc is planning to pour billions of euros into a hydrogen economy that will decarbonise industry and help keep Europe competitive.

Its definition of renewable hydrogen has been influential on the world stage – likely to be replicated overseas in the United States – and it has set vital targets under the Renewable Energy Directive for the uptake of renewable hydrogen in industry to rise to 60% by 2035.

Yet the announcement of clean energy subsidies under the US Inflation Reduction Act undermined the EU’s position as a global hydrogen leader, as the US sets a high bar for clean hydrogen investment.

Fresh opportunity – and risks

Those with their finger on the pulse understand that this low-carbon definition has big implications: it is the key to ensure that EU hydrogen helps rather than hinders the energy transition, and therefore the competitiveness of European industry.

The definition, in the form of a delegated act, will put forward specific conditions to calculate the life-cycle emissions of low-carbon hydrogen. It will largely apply to what is widely known as blue hydrogen, made from natural gas with carbon capture and storage (CCS).

There are real risks. Low carbon does not equal low emissions, with emissions from both methane and hydrogen itself also part of the blue hydrogen life cycle.

Leaking across the blue hydrogen supply chain, both of these gases have global warming potentials many times that of carbon dioxide (CO2). In the first 20 years after their release into the atmosphere, hydrogen emissions are 35 times more potent than CO2, while methane emissions are 84 times more potent.

Because of this, hydrogen made from fossil fuels with CCS has the potential to release a cocktail of emissions with warming impacts up to 50% worse than traditional fossil fuels, according to a recent peer-reviewed study.

A clean definition

The starting point of any low-carbon hydrogen definition must be renewable hydrogen. Made from renewable electricity, it is the only near-zero emissions hydrogen.

The EU’s standard for renewable hydrogen allows 3.38kg of CO2-equivalent (CO2e) emissions for every kilogram of hydrogen produced and distributed to end users in a full lifecycle approach – defined as a 70% emissions saving compared to fossil fuel comparators.

This implies a more lenient production threshold than what my colleagues and I at the Hydrogen Science Coalition recommend with our clean hydrogen definition, which sets a threshold of 1kg of CO2e per kilogram of hydrogen.

This represents achievable emission savings of more than 90% and is consistent with reaching net-zero by 2050. It should be striven for as an end point for all hydrogen production.

The EU’s definition of low-carbon hydrogen will set at least the same 70% emissions saving threshold as for renewable hydrogen – making it vital that it lays out an accounting scheme that ensures with accuracy that blue hydrogen production and distribution respect this starting point threshold.

First, all energy inputs must be guaranteed to be clean, with transparent third-party verification of all energy, such as electricity used in hydrogen production and carbon capture, along with similar third-party verification of all emissions, including methane, throughout the gas supply chain to fully account for upstream emissions.

Second, low production CO2e emissions must be guaranteed, beyond carbon alone to also include hydrogen and methane leakage across the full life cycle.

Third, CCS performance must be meticulously evaluated, with low CO2e emissions from CCS process energy and the long-term permanence of storage guaranteed. Carbon capture rates and leakage rates must be rigorously monitored.

Finally, all of this data must be independently verified by approved auditors, ensuring that reported information corresponds to real-world data rather than averages, and that at no stage is the emissions threshold exceeded.

A challenge worth rising to

The above conditions will be challenging for the blue hydrogen industry to meet – both in terms of sourcing natural gas and the effectiveness of CCS technology.

However, meeting this standard is what is required to produce hydrogen that will be successful in reducing emissions out to 2050. Rising to this challenge will ensure that the EU builds a hydrogen economy with longevity, preventing future stranded assets, wasted investment of valuable public funds, and continued reliance on fossil fuel energy imports.

It will also ensure a level playing field in the hydrogen industry: giving confidence that any hydrogen used in the EU meets the same standard of clean, simplifying hydrogen trade, and ensuring subsidies for hydrogen manufacture do not favour one sector over another..

The current Commission has one final opportunity to lay the foundation for a strong hydrogen legacy. Will it rise to the challenge?